FAQ: During the window, can an LPFM station still claim a point for pledging to broadcast 12 hours per day?

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That was valid only for the orignal 2000/2001 window series.  This rule was changed in 2012 in the Sixth Report and Order.  As of June 2019, the points are earned as follows:

  1. Established Community Presence - applicant must, for a two year period prior to filing, have qualified as local (defined as being within 20 miles of the transmitting antenna except in markets 1 through 50 where the distance is reduced to 10 miles).  The organization must maintain the local presence afterwards.
  2. Local Program Origination - applicant pledges to carry a minimum of 8 hours of programming a day that originates from any point within 10 miles of the transmitting antenna (regardless of market size).  
  3. Main Studio - applicant pledges to maintain a publicly accessible main studio that has local program origination capability and is accessible by phone for at least 20 hours per week and be located within 20 miles of the transmitter except for markets 1-50 where the distance is reduced to 10 miles.  (This point is still in effect despite the FCC's elimination of main studio requirements for full-service broadcast stations).
  4. Local Program Origination and Main Studio - If both points 2 and 3 are claimed, then a bonus point can be claimed.
  5. Diversity of Ownership - An applicant must hold no attributable interest in any other broadcast station.
  6. Tribal Applicants serving tribal lands - The applicant must be a tribal applicant and the transmitting antenna must be located on tribal land.

LPFM stations are only required to hold the local program origination and main studio pledges if, at the end of the filing window and subsequent remediation windows, their points were necessary to eliminate another applicant from contention.  If, prior to the original grant, the applicant makes a move to break out of the mutually exclusive (MX) group of applicants, or another applicant in the same MX group makes a change or is otherwise dismissed prior to the Commission's final decision thus making your application "singleton", you are absolved of meeting those pledges.

If you reach a time share agreement that involves all applicants in the group and does not result in the elimination of any applicant, then you are absolved from the pledge requirements.   For example:

  • The MX group has three 5 point applicants and no 4 point applicants.  All three applicants reach a time share agreement (or a settlement is reached where two applicants time share and one is voluntarily dismissed), then the group is absolved of the pledges.
  • The MX group has three 5 point applicants and a 4 point applicant, the 4 point applicant is unable to move and either (1) all three of the 5 point applicants reach a time share agreement, (2) two of three 5 applicants reach a time share agreement, or (3) no time share agreements are reached and the FCC defaults the group to mandatory time sharing, then the applicants in the group are subject to the pledge.
  • The MX group has two 5 point applicants and one 4 point applicant.  One of the 5 point applicants was able to change to a different channel and become singleton.  That applicant will not be subject to the pledge.  If neither the 4 or 5 point applicant are able to move, the 5 point applicant will win the channel over the 4 point applicant but will be subject to the pledge because their points eliminated the 4 point applicant.

For a list of 2013 window LPFM stations that are subject to the pledge, please see https://recnet.com/pledges

It is also important to note that LPFM stations that regularly do not operate 12 hours a day are subject to mandatory time sharing if a challenging application is filed during the renewal cycle.


LPFM during the filing window
Answer Date: 
Tuesday, June 25, 2019